People v.

Romualdez - Romualdez allegedly altered the BAR exam grades of Mabunay and was charged with the crime of falsification of public documents. Accused was secretary of justice who was chairman of bar committee. In her defense, she said she was given authority to revise compositions already reviewed. SC said shes guilty. She knew it was Mabunays exam she was altering. Exams are public documents. Her act is covered by pars. 2, 3, and 6 of Art. 300/171. Dissent said that her cosupervisor also changed grades in the same way. Also, her acts would only constitute abuse of authority. Beradio v. CA - Accused atty. was appointed election registrar of COMELEC. She requested to be counsel of cousins which comelec granted. Problem here was her daily time records showed she was always present even if she was not. She was charged under art. 171(4). SC said that there was no dolo because her absences were all less than an hour and merely fulfilling her duty to give free aid. CAR was just 2 meters away. Acquitted. Luague v. CA - Wife of deceased teacher clerk encashed his salary warrants using his name. She was charged with estafa thru falsification of commercial documents. She contends that she did it in good faith and no criminal intent. SC said she is not guilty. CA applied the letter of the law too literally. They failed to take into account that she used money for burial etc. There is an absence of damage. Cabigas v. People - Accused is securities custodian of land bank. During inventory of notes and bills, he discovered the loss of 6 treasury bills with a value of 3m pesos. They then changed the last 2 digits of the serial numbers for 19 treasury notes. They reported the missing bills. NBI investigated tapos yun pala the branch manager Pigram used those to secure a loan. Cabigas and Reynes arrested for alleged conspiracy. SC said not all elements under 171(4) were present. He changed serial numbers according to his duty. People v. Sandaydiego page 204 reyes - Provincial treasurer Sandaydiego together with other accused used six forged provincial vouchers in order to embezzle 57k pesos for bridge and road fund. Siquian v. People - Accused is mayor and he was charged of falsification under 171(4). He appointed Carreon to a position that did not exist and certifying that funds existed for this job. He contended that there was no intent. SC said he is guilty and met all the elements. He knowingly made false certification when he said funds were available for that fake job. People v. Villalon - Document of mortgage was falsified by accused alleging that he has obtained the signatures of the De Guzman brothers. Falsification of a document may be a means of committing estafa because before the document is used it was already falsified, damage or intent not being an element of falsification. Hence, falsification is only a necessary means to commit estafa. -